ML20034G296
| ML20034G296 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/03/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20034G293 | List: |
| References | |
| 50-498-92-35, 50-499-92-35, NUDOCS 9303090297 | |
| Download: ML20034G296 (4) | |
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APPENDIX A NOTICE OF VIOLATION Houston Lighting & Power Company Dockets:
50-498 i
South Texas Project, Units 1 and 2 50-499 Licenses:
NPF-76 NPF-80 During an NRC inspection conducted November 30, 1992, through January 12, 1993, four violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR 2, Appendix C, the violations are listed below:
A.
Criterion XVI to 10 CFR 50, Appendix B, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure t
that the cause of the condition is determined and corrective action taken to preclude repetition.
Procedure OPGP03-ZX-0002, Revision 0,
" Corrective Action Program," Section 4.1, Station Problem Report Instruction, requires that, "any person at STPEGS who identifies or becomes aware of a Condition Adverse to Quality (CAQ) or Significant Condition Adverse to Quality (SCAQ) SHALL promptly document the occurrence using an SPR Form." Four examples of violating these requirements are stated below:
j 1.
Contrary to the above, a station problem report was not promptly initiated to document tne foreign material (rust like particles) found on the Emergency Diesel Generator 23 fuel oil strainers on December 4, 1992. This nonconforming condition was identified during the performance of Service Request D0-186915 to replace the strainers.
2.
Contrary to the above, prompt corrective actions were not initiated to correct equipment deficiencies with Essential Chiller 21A.
Plant Equivalency Change-CH-178119 was initiated in June 1992 to correct a condition which permitted the upper oil reservoir to migrate to the lower reservoir, requiring the essential chiller to be declared inoperable in accordance with l
Technical ' Specification 3.7.14 On December 9, 1992, the Essential Chiller 21A was declared inoperable because the essential chiller did not have sufficient indicated oil level
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showing in the upper reservoir.
Plant Equivalency Change CH-178119 had not been initiated and no date had_been t
established for implementing the plant equivalency change.
l 3.
Contrary to the above, as of December 17, 1992, the licensee had not identified the cause for the repetitive problems with Auxiliary Feedwater Turbine 24 overspeed trip mechanism and had l
taken no corrective actions to preclude the recurrence of the problem.
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4.
Contrary to the above, the corrective action taken to a violation documented in NRC Inspection Report 50-498/91-11; 50-499/91-11 involving individuals working more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, was not adequate to preclude repetition. During the j
inspection, four individuals were' identified to have exceeded j
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> worked in a 7-day period without plant manager approval.
j One occurrence involved an instrumentation and controls technician, with three additional occurrences involving electrical j
maintenance personnel.
i These four examples constitute one Severity Level IV violation.
(Supplement 1) (498;499/9235-02) f B.
Technical Specification 4.8.1.1.2.e.ll requires that "Each standby e
diesel generator shall be demonstrated OPERABLE... at least once per l
18 months, during shutdown, by... verifying that the automatic load
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sequence timer is OPERABLE with the first sequenced load verified to be loaded within 1.0 second and 1.6 seconds, and all other load blocks within + 10% of its design interval..."
Contrary to the above, Surveillance Procedures 1/2-PSP 02-SF-0001A/lB/1C/2A/2B/2C, "ESF Diesel Sequencer IA/lB/IC/2A/2B/2C Timing
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Test," did not verify the entire time sequence corresponding to the r
loading of the essential chillers.
These procedures only verify the time sequence to the point at which the chiller units receive a start-signal and the unit compressor oil pumps are loaded (a fraction of the chiller unit load).
The time delay introduced by the timers which were internal to the chillers was not tested.
i This is a Severity Level IV violation.
(Suoplement 1) (498;499/9235-03)-
l C.
Technical Specification 6.11.1 states that procedures for personnel radiation protection shall be prepared consistent with the requiremer.ts of 10 CFR 20 and shall be approved, maintained, and adhered to for all 4
operations involving personnel radiation exposure. Two examples of violating this requirement are stated below.
i 1.
Procedure OPGP03-ZR-0002, Revision 9,. " Radiological Controlled j
Area Access and Work Control," Step 5.5,. states, in part, that, when exiting the radiologically restricted area, personnel will I
use a personnel contamination monitor and, if not available, wil.1 perform a whole-body frisk as directed by Health Physics.
Contrary to the above, on December 7, 1992, a licensee worker i
exited the Unit I radiologically restricted area without utilizing a t irsonnel contamination monitor or performing a whole-body i
frisk.
i 2.
Procedure OPRP02-ZX-0007, Revision 5, " Radiological Posting and Warning Devices," Paragraph 4.2.2 requires, in part, that, the i
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. radiological postings signs be hung from barriers such that the posting is clearly visible when approaching the area.
Paragraph 4.3 establishes areas as requiring radiological postings as any area where access is controlled by HP for purposes of protection of individuals from exposure to ' radiation and or radioactive materials.
Areas outside the main Units 1 and 2 radiologically controlled area (RCA) should be identified as an RCA if the dose rates at 18 inches exceed 0.5 mr/hr.
Contrary to the above, on December 4,1992, the radiological posting was not adequate to restrict personnel access from an area outside the main Units 1 and 2 RCA where dose rates exceeded O.5 mr/hr at 18 inches.
During a radiation monitor calibration, while the source'was exposed, a licensee employee entered into the i
Unit 2 control room through the south door and violated the radiological posting in place for the surveillance.
The radiological posting sign had been hung from the door and not from j;
barriers such that the posting was not clearly visible when approaching the door.
This is a Severity Level IV violation.
(Supplement 1) (498:499/9235-05)
P D.
Technical Specification 6.lB.I.h requires that written procedures shall 4
be established, implemented, and maintained covering the activities of the fire protection program. Two examples of violating this requirement are stated below.
i 1.
Procedure OPGP03-ZF-0004, Revision 1, " Control of Transient Fire Loads," Paragraph 4.1, requires that wood shall not be used in i
areas containing safety-related equipment or systems unless
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noncombustible substances are not commercially available. Wood.
j products (scaffolding, platforms, lay down blocks, etc.) shall not.
be taken into such areas earlierfthan necessary to support ~ work-j activities.
i Contrary to the above, on December 12, 1992, it was identified that a wooden folding table and wooden scaffolding material were.
l being stored in the safety-related Emergency Diesel Generator 23 l
room.
2.
Station Procedure OPGP03-ZF-0018, Revision 6, " Fire Protection System Operability Requirements," paragraph 4.8 requires, in part, j
... SEAllHG DEVICES in fire rated assembly penetrations (fire-i doors; fire dampers; and cable, piping and ventilation duct i
penetration seals) shall be operable whenever equipment protected by the fire rated assemblies is required to be operable by the
.i Technical Specifications."
The South Texas Project Electrical Generating Station Updated.
Final Safety Analysis Report (UFSAR) 3.1.2.1.3 states, in part, j
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" Evaluation Against Criterion 3 - The plant has been designed in accordance with the recommendations of the National Fire Protection Association.
3 The National Fire Protection Association National Fire Code, 1975 version, requires, in part, "2-2.5.1 Flush-Mounted.
Clearances for flush-mounted doors shall not exceed 3/4 inches at'
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the sill."
I Contrary to the above, on December 6, 1992,-it was identified that l
the clearance for flush-mounted Unit ! Door 23, which protects the uxiliary shutdown panel, was 1 1/4 inches at the sill. This condition has existed since issuance of the operating license.
This is a Severity Level IV violation.
(Supplement I) (498;499/9235-06) j Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, and a copy to
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the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis _ for disputing the violation, (2)- the
-i corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or demand for
-l information may be issued as to why the license should not be modified, i
suspended, or revoked, or why such other action as may be proper should not be.
taken. Where good cause is shown, consideration will be given to extending
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the response time.
i Dated at Arlington, Texas, this day of 1993 l
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